UK/EU Recruitment Privacy Notice

What is the purpose of this document?

Payward Ltd. and its subsidiaries is committed to protecting the privacy and security of your personal information.

This privacy notice describes how we collect and use personal information about you during and after your working relationship with us, in accordance with the EU General Data Protection Regulation (GDPR) 2016, and the UK Data Protection Act (DPA) 2018.

It applies to all job applicants.

1. Payward Ltd. is a "data controller". This means that we are responsible for deciding how we hold and use personal information about you. We are required under data protection legislation to notify you of the information contained in this privacy notice.

2. This notice applies to job applicants and those applicants who proceed through the recruitment process. This notice does not form part of any contract of employment or other contract to provide services. We may update this notice at any time but if we do so, we will provide you with an updated copy of this notice as soon as reasonably practicable.

Data protection principles

We will comply with data protection law. This says that the personal information we hold about you must be:

1. Used lawfully, fairly and in a transparent way.

2. Collected only for valid purposes that we have clearly explained to you and not used in any way that is incompatible with those purposes.

3. Relevant to the purposes we have told you about and limited only to those purposes.

4. Accurate and kept up to date.

5. Kept only as long as necessary for the purposes we have told you about.

6. Kept securely.

The kind of information we hold about you

Personal data, or personal information means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).

There are certain types of more sensitive personal data which require a higher level of protection, such as information about a person's health or sexual orientation. Information about criminal convictions also warrants this higher level of protection.

If you apply to work for us, we will collect a range of information from you, including your name, home address, date of birth, email address, telephone number as well as your employment history. This is referred to as your “personal information”.

1. We will also collect sensitive information from you (known as “special categories of data”) which includes:

   1. your racial or ethnic origin;
   2. religion;
   3. sexual orientation;
   4. any disabilities which you may have;
   5. health conditions that you have in order for us to make reasonable adjustments to your work environment.
       

   Please be advised that we treat all special categories of data with extra security ensuring specifically that only authorised individuals are able to access it. This is additional to the technical controls that we routinely apply to all data.

2. We will collect personal information from you directly, normally via your resume (CV) which you have shared with us.  We may also collect information from you when corresponding with you by telephone, digital chat channels, email and letters. Please note that should you be successful in your application, all of this information may form part of your employment record.

3. Please also be advised that when you visit this website, and even if you do not make a job application, cookies will be used to collect information about you, such as your Internet Protocol (IP) address, which connects your computer or mobile device to the Internet, and information about your visit, such as the pages you viewed or searched, page response times, downloaded errors etc.  We do this so that we can measure our website performance and make improvements in the future.  Cookies are also used to enhance this website’s functionality, which includes sharing data with our web management team.  You can control this by adjusting your cookies settings.

How we will use information about you

We will only use your personal information when the law allows us to. Most commonly, we will use your personal information in the following circumstances:

1. To fulfil contractual obligations, this includes taking action before entering into a contract.
2. Where we need to comply with a legal obligation.
3. Where it is necessary for legitimate interests pursued by us or a third party and your interests and fundamental rights do not override those interests.

We use the information collected from you for the purposes listed in the table below.

If you fail to provide personal information

1. If you fail to provide certain information when requested, we may not be able to proceed with your application, or we may be prevented from complying with our legal obligations.

Change of purpose

1. We will only use your personal information for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If we need to use your personal information for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.

2. Please note that we may process your personal information without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.

Transferring information outside the EU and UK

We will transfer the personal information we collect about you to the US in order to perform our contract with you. There is an adequacy decision by the European Commission and UK in respect of US companies who register with the EU-US Privacy Shield Framework.

Data security

1. We limit access to your personal information to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal information on our instructions and they are subject to a duty of confidentiality.  

2. We have put in place procedures to deal with any suspected data security breach and will notify you and any applicable regulator of a suspected breach where we are legally required to do so.

Data retention

How long will you use my information for?

1. We will only retain your personal information for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal or reporting requirements. Typically, we will retain your information for a period of 12 months, and beyond this period if we have your consent.

Rights of access, correction, erasure, and restriction

Your duty to inform us of changes

Your rights in connection with personal information

1. It is important that the personal information we hold about you is accurate and current. Please keep us informed if your personal information changes during the recruitment process with us. 

2. Under certain circumstances, by law you have the right to:

   1. Request access to your personal information (commonly known as a "data subject access request"). This enables you to receive a copy of the personal information we hold about you and to check that we are lawfully processing it.
   2. Request correction of the personal information that we hold about you. This enables you to have any incomplete or inaccurate information we hold about you corrected.
   3. Request erasure of your personal information. This enables you to ask us to delete or remove personal information where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal information where you have exercised your right to object to processing (see below).
   4. Object to processing of your personal information where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground. You also have the right to object where we are processing your personal information for direct marketing purposes.
   5. Request the restriction of processing of your personal information. This enables you to ask us to suspend the processing of personal information about you, for example if you want us to establish its accuracy or the reason for processing it.
   6. Request the transfer of your personal information to another party.

If you want to review, verify, correct or request erasure of your personal information, object to the processing of your personal data, or request that we transfer a copy of your personal information to another party, please contact the Data Protection Officer in writing via support@kraken.com

No fee usually required

1. You will not have to pay a fee to access your personal information (or to exercise any of the other rights). However, we may charge a reasonable fee if your request for access is clearly unfounded or excessive. Alternatively, we may refuse to comply with the request in such circumstances.

What we may need from you

1. We may need to request specific information from you to help us confirm your identity and ensure your right to access the information (or to exercise any of your other rights). This is another appropriate security measure to ensure that personal information is not disclosed to any person who has no right to receive it.

Right to withdraw consent

1. In the limited circumstances where you may have provided your consent to the collection, processing and transfer of your personal information for a specific purpose, you have the right to withdraw your consent for that specific processing at any time. To withdraw your consent, please contact the Data Protection Officer via support@kraken.com  Once we have received notification that you have withdrawn your consent, we will no longer process your information for the purpose or purposes you originally agreed to, unless we have another legitimate basis for doing so in law.

Data protection officer

1. We have appointed a Data Protection Officer (DPO) to oversee compliance with this privacy notice. If you have any questions about this privacy notice or how we handle your personal information, please contact the DPO at support@kraken.com  You have the right to make a complaint at any time to your country privacy and data protection authority or regulator.

Changes to this privacy notice

1. We reserve the right to update this privacy notice at any time, and we will provide you with a new privacy notice when we make any substantial updates. We may also notify you in other ways from time to time about the processing of your personal information.